OSHA – Commercial Diving
Standard – 1910 Subpart T
Many public safety dive teams are under the assumption that the OSHA CDS does not apply to them. There are a number of questions that you must ask yourself before being able to answer if it applied to you. Is your dive team operating in a Federal OSHA state or a state plan state? If you are in a Federal OSHA state then the standard does not apply to state, local and volunteers. If you are in a state plan state and you are a state or local dive team then it does apply to you. Volunteers in a state plan state may or may not fall under the regulations depending on how your state views volunteers. So, as you can see, it’s not always that simple. Even if OSHA does not cover your department, the CDS is a good guideline that can help your team to formulate a solid plan and protect your divers. The Commercial Diving Standard is 91 pages long and too much to get into here but let’s look at a couple highlights in regards to the medical side.
Much like the Exposure Control Plan that most EMS or fire departments have to have for a bloodborne exposure, OSHA requires dive teams to have a Safe Practice Manual. This manual is expected to be present at every dive and in a place that every diver can find it. This manual should outline everything that we will talk about here and more, to include how a dive mode will be conducted and how an emergency will be handled.
Each diver should be getting a proper medical assessment prior to getting into the water, this is a great chance for you to also see how they are doing mentally and physically. Diving is very hard on the body and a full set of vital signs should be taken on every diver prior to gearing up. I have pulled a number of divers from training and missions due to issues with high blood pressure or having difficulty clearing. Too many public safety divers have died from medical complications during a dive. Preventing someone from diving when they are not healthy enough to, may just save their life.
Once divers are checked out, they need to be briefed on any safety hazards that may affect their dive. This includes upper and lower lever water currents, incoming weather or electrical issues like aeration fountains. Once the briefing has been concluded they should do a full gear check and get everything recorded in the log. Time of the year would dictate how your overall scene setup should be. Cold weather should have divers and gear protected from the cold, while the heat of the summer requires proper hydration and protection from the sun. Your plan should already be in place and outlined as to how you will respond in a medical emergency. What hospital will you transport to for medical problems? Where is the closest chamber in the event of a DCI? How will they be transported out, medic unit? Hello? Does anyone even know where to find you, if you call for help on the phone or radio?
These are all things that must be considered before anyone gets wet. Each team member must also be trained in first aid and CPR and have a proper understanding of how dive physics will affect their bodies. Certain medical items including a properly stocked first aid kit, bag valve mask and oxygen should all be available at the dive site.
During the Dive
Divers must have a safe way of getting into the water and getting back out. This is usually a ladder that extends down into the water, but often it is just a safe place to walk up on shore. There should be a way to evacuate a diver in an emergency from the water and most teams will use a device like a stokes basket or backboard.
The biggest danger other than the divers actively in the water is the 90 percent diver. The 90 percent diver is the one usually sitting and waiting to be deployed. If properly geared up, they will be the one that needs to be monitored on a regular basis. Sitting in a dry suit waiting for an emergency, can be dangerous to your bodies core temperatures. They should have a tender assigned to make them as comfortable as possible.
Dive profiles need to be recorded and tracked at all times. Many dive computers can be downloaded into a laptop via USB and brought to the hospital if needed to show the hyperbaric docs. Dive computers are a great tool to help keep you out of trouble, but they are all based on theoretical profiles and are not full-proof. There have been a number of studies by the Divers Alert Network on divers that have been bent even after following their computer to the letter.
The dive ends once the diver surfaces. At that point the 10-minute AGE (Arterial Gas Embolism) clock starts. Divers need to be watched during those first 10 minutes for any signs of an AGE. Don’t let them leave your sight during this time. Use these 10 minutes to check their vitals again, give them a rapid set of neuros, hydrate and rest. Once the 10-minute window closes they are safe from AGE and now just need to know they should watch for symptoms of DCS for the next 24 hours. Any symptoms of DCS needs to be documented and treated.
There is so much to know about the OSHA Commercial Diving Standard, much more than we have time for here. The North Carolina Department of Labor has also created an Industry Guide that follows the CDS and can help you wade through some of the requirements. Go to their website www.labor.nc.gov, go to safety and health, publications and then click on Industry Guides. On the Dive Medic side, there are some great resources online as well. The Navy Dive Manual has some outstanding information in it and it is free to download. Again, it’s a heavy document at about 1000 pages, but there is a whole section on Dive medical information.
If you have any questions about the CDS, or any Dive Medical questions please let me know, and remember to keep those divers safe!